General Project BackgroundThe Texas Regional Institute for Environmental Studies (TRIES) had received a grant from the Army Research Office (ARO) to assist Army installations engaging in certain industrial operations, one of which was the preparation of Federal Operating Permit (FOP) applications required by the Clean Air Act Amendments of 1990. The TRIES partnered with Environeering, Inc. to work with Industrial Operations Command's Air Quality Office in this ongoing project. The project's final phase I deliverable, "Methodology Guidance Document for Preparation od Federal Operationg Permits at U.S. Army Installations", presents a generalized approach that can be used to assist Army installations in preparation of their FOPs.
As part of this project, two existing Army installations were selected as models for the methodology development. Due to recent base realignment mandates, one of these installations, the Longhorn Army Ammunition Plant (LHAAP), is currently inactive. The LHAAP was used to demonstrate an installation which could choose to avoid the FOP program because of limited actual and potential emissions. The second installation, the Lone Star Army Ammunition Plant (LSAAP), was used to model an active installation of moderate size to which the FOP program would apply. The results of the FOP applicability determination for each of the model facilities were submitted as separate project activities.
Thus, the project's methodology guidance document presents a demonstrated, accepted approach to be used at Army installations preparing of their FOP's. Currently, the project team has initiated a second phase of the project at the Red River Army Depot, a facility with different activities, but similarly subject to FOP compliance and to which the methodology is applicable.
Model Installations' BackgroundsThe LHAAP is a government-owned, contractor operated (GOCO) facility. The LHAAP is located in the northwest corner of Harrison County, Texas, near the Louisiana border. The installation covers 8,500 acres and was responsible for manufacture of propellants and other materials, as well as loading, packing and assembly of pyrotechnic signals and rocket motors. At the time of the study, active portions of the installation included an administration area, research and development facility, minor production lines, power plant, extruder facility, open burning ground, test firing area, potable water and wastewater treatment plants, and fire station.
The LSAAP is also a GOCO ammunition production installation. The LSAAP is located in northeast Texas, in Bowie County, near the city of Texarkana, Texas, thus twenty miles from the Arkansas border. The installation is comprised of approximately 16,000 acres. It is responsible for the production of a variety of munitions and, as its name indicates, those functions necessary to load, assemble and pack ammunition items. Active portions of the installation include an administration area, production load lines, storage areas, maintenance shops, chemistry laboratory, printshop, woodworking shop, railroad classification yard, sewage treatment plant, demolition/ burning grounds, landfills and fire-fighting pumping station.
Generalized FOP Preparation RequirementsTo quickly determine an installation's classification, the three simple tasks are required:
- Conduct a review of the installation's emission inventories over the previous two years, (if available).
- Conduct a review of all existing permits or otherwise authorized emissions (such as permit exemptions, registrations, etc.).
- Target specific emissions sources for calculation of individual source's maximum potential to emit.
Once the initial screening has indicated that an installation is potentially subject to the FOP program, the necessary steps for preparation of the permit application are identified as follows.
- Inventory all potential or actual emissions sources within a contiguous installation boundary. This boundary may be actual (physical) or operational (under the same administrative branch or responsible official)
- Characterize emissions from these sources (for example, VOCs, products of combustion, etc.).
- Calculate maximum potential to emit for all sources not considered insignificant. (The EPA has designated certain sources as insignificant. Other insignificant sources at the installation are those which alone comprise less than 1% of the total emissions for that contaminant or whose emissions are less than 0.1 tons/year).
- Compare the calculated maximum potential to emit for the installation to major source thresholds for the air quality region in which the installation resides.
- Evaluate the potential to limit emissions below threshold quantities.
- If major source classification is evident, review all applicable Federal and State air regulations that could potentially apply to one or more of the sources at the installation.
- Compile pertinent emission source records and documentation.
- Determine compliance status at each source, generate a list of noncompliance issues.
- Attempt to resolve noncompliance issues by taking corrective action, applying for State new source review or preconstruction authorization permits, qualify for permit exemptions or general permits, or institute new installation procedures.
- Prepare a strategy for bringing all noncompliant sources into compliance. This will include preparation of an installation-wide compliance plan, schedule for action and necessary budgeting to cover costs for modifications.
- Designate a responsible official for certifying installation compliance and implement employee training.
- Devise and implement, on a trial basis, a self-monitoring and record keeping program to demonstrate compliance. Work out problem areas encountered in order to refine the plan for submittal in the FOP application.
- Devise alternate operating scenarios for the installation and evaluate their impact on installation emissions. If an alternate operating scenario would trigger new requirements, or possibly, new source review, include that alternate scenario in the FOP application.
- Prepare FOP application documents and submit application.